An island-based yacht management company has been fined more than £4,000 for not complying with regulations designed to thwart money-laundering.
The Financial Services Authority penalised Dohle Yacht Management Services Limited under section 27 of the Designated Businesses (Registration and Oversight) Act 2015.
Dohle was found to have breached anti-money laundering rules as well as the Countering the Financing of Terrorism code.
The civil penalty imposed on Dohle, which is based at Fort Anne on the South Quay in Douglas, is the sum of £5,896 which is discounted by 30% to £4,127.
The FSA said the level of the penalty reflected the fact that Dohle had co-operated with the authority and agreed settlement at an early stage.
Dohle has been registered with the FSA as an external accountant since October 2017.
Its 2020 annual return to the FSA indicated high proportion of foreign politically exposed persons.
An inspection in April 2022 identified a significant number of contraventions of the Code by Dohle across its foreign politically exposed persons client base.
The authority told Dohle to suspend all existing and established business relationships and refrain from establishing any new business relationships until the authority could be satisfied that it could demonstrate its compliance with the code.
Following the inspection, Dohle had decided to cease providing the services of an external accountant and has subsequently requested that the authority de-register under the Act.
The FSA said that Dohle had engaged positively ty throughout this matter in a timely and constructive manner.
Contraventions of the code identified by the inspection included:
The firm’s business risk assessment was not up-to-date and did not include an overall assessment of the risk of money laundering and terrorist financing of its business or its customers.;
The customer risk assessments of Dohle did not contain the prescribed level of detail nor were they updated on a regular basis
Code-compliant customer due diligence and enhanced due diligence was not on file in all cases.
The foreign politically exposed persons customer files did not adequately demonstrate or identify customers source of funds and source of wealth.
The ongoing monitoring processes of Dohle were not effective
Monitoring and testing of Dohle’s compliance with the code was not undertaken
Dohle failed to establish procedures and controls which were suitable or appropriate to take into account the risks posed to DYMSL, nor the specific processes relevant to the same